Correspondence 0001731122-23-001951 from Innovation Beverage Group Ltd (IBG) (CIK 0001924482) (IBG)
Innovation Beverage Group Ltd (IBG) (CIK 0001924482)
Date: Oct. 25, 2023 · CIK: 0001924482 · Accession: 0001731122-23-001951
AI Filing Summary & Sentiment
File numbers found in text: 333-266965
Letter
Division of Corporation Finance Office of Manufacturing Securities and Exchange Commission Re: Innovation Beverage Group Ltd Amendment No. 20 to the Registration Statement on Form F-1 File No. 333-266965 Filed October 11, 2023
Dear Messrs. Ingram and Ewing:
On behalf of Innovation Beverage Group Ltd. (the “Company”), this letter responds to comments provided by the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the Company on October 23, 2023 regarding the Company’s Registration Statement on Form F-1 (the “Registration Statement”). Changes made in response to the Staff’s comments have been made in our amendment to the Registration Statement (the “Amended Registration Statement”), which is being filed with the Commission contemporaneously with the submission of this letter.
For convenience, the Staff’s comments have been restated below and the Company’s response is set out immediately under the restated comments. Unless otherwise indicated, defined terms used herein have the meanings set forth in the Amended Registration Statement.
Amendment No. 20 to Registration Statement on Form F-1
December 31, 2022 Audited Financial Statements
Note 11. Reportable Segments, page F-18
1. It appears the title heading for Note 11, Reportable Segments, has been erroneously omitted from the December 31, 2022 audited financial statements in this amendment. Please revise accordingly.
Response: The Company acknowledges the Staff’s comment and has made the requested correction to page F-19.
June 30, 2023 Unaudited Interim Consolidated Financial Statements Index to Consolidated Financial Statements (Unaudited), page F-22
2. We have reviewed your response to prior comment one. Given that the June 30, 2022 comparative interim period has been audited, please provide in the filing an auditors’ report covering the six months ended June 30, 2022. Also, the Experts section at page 126 should be updated for this interim period, along with providing an updated accountant’s consent covering this same interim period. Please revise or advise.
Response: The Company acknowledges the Staff’s comment and has included the auditors’ report for the six months ended June 30, 2022 at page F-2, revised the Experts section at page 126 and provided an updated auditors’ consent in Exhibit 23.1.
Should you have any questions regarding the foregoing, please do not hesitate to contact the Company’s counsel, Darrin Ocasio, of Sichenzia Ross Ference Carmel LLP at (212) 930-9700.
Sincerely,
Dean Huge
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INNOVATION BEVERAGE GROUP LTD.
29 Anvil Road
Seven Hills, NSW 2147 Australia
October 25, 2023
Division of Corporation Finance
Office of Manufacturing
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attn: Jay Ingram and Evan Ewing
Re:
Innovation Beverage Group Ltd
Amendment No. 20 to the Registration Statement on Form F-1
File No. 333-266965
Filed October 11, 2023
Dear Messrs. Ingram and Ewing:
On behalf of Innovation
Beverage Group Ltd. (the “Company”), this letter responds to comments provided by the staff of the Division of Corporation
Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to the Company
on October 23, 2023 regarding the Company’s Registration Statement on Form F-1 (the “Registration Statement”).
Changes made in response to the Staff’s comments have been made in our amendment to the Registration Statement (the “Amended
Registration Statement”), which is being filed with the Commission contemporaneously with the submission of this letter.
For convenience, the Staff’s
comments have been restated below and the Company’s response is set out immediately under the restated comments. Unless otherwise
indicated, defined terms used herein have the meanings set forth in the Amended Registration Statement.
Amendment No. 20 to Registration Statement on Form F-1
December 31, 2022 Audited Financial Statements
Note 11. Reportable Segments, page F-18
1.
It appears the title heading for Note 11, Reportable Segments, has been erroneously omitted from the December 31, 2022 audited financial statements in this amendment. Please revise accordingly.
Response: The Company acknowledges the Staff’s
comment and has made the requested correction to page F-19.
June 30, 2023 Unaudited Interim Consolidated Financial
Statements Index to Consolidated Financial Statements (Unaudited), page F-22
2. We have reviewed your response to prior comment one. Given that the June 30, 2022
comparative interim period has been audited, please provide in the filing an auditors’ report covering the six months ended June
30, 2022. Also, the Experts section at page 126 should be updated for this interim period, along with providing an updated accountant’s
consent covering this same interim period. Please revise or advise.
Response: The Company acknowledges the Staff’s
comment and has included the auditors’ report for the six months ended June 30, 2022 at page F-2, revised the Experts section at
page 126 and provided an updated auditors’ consent in Exhibit 23.1.
Should you have any questions
regarding the foregoing, please do not hesitate to contact the Company’s counsel, Darrin Ocasio, of Sichenzia Ross Ference Carmel
LLP at (212) 930-9700.
Sincerely,
Dean Huge
Chief Executive Officer
cc:
Darrin Ocasio, Esq.